APPENDIX 2

Private Hire Vehicle Age, MOT and Retrofit Requirements

Current Policy Consultation Proposal Recommended Policy Commentary

1. Emissions No Change from current policy The emission standard that is This is a significant change from
applicable to vehicles from 1st January the consultation proposal. The
Birmingham City Council will not
2020 will be repealed. In its place we recommendation is to remove
license or permit the use of any will apply a strict age policy for private the emissions standard as the
vehicle as a private hire vehicle after hire vehicles which will be a maximum criteria for licensing vehicles and
31 December 2019 that does not of 12 years (see section 2 below). This to replace it with a strict age
meet the minimum emission policy will apply from 1st January 2020. policy. This will ensure that
standards of Euro 4 for petrol engines, significantly more private hire
Euro 6 for diesel engines or is Ultra
vehicles are still working after 1st
Low Emission or a Zero Emission January 2020. Under the
Capable Vehicle. Vehicles that do not meet the CAZ
emission standards for their type of proposed policy 3,621 vehicles
fuel will not be exempted from paying would need to be replaced,
the daily CAZ charge. under the recommended policy
only 1,442 will need to be
replaced which are the oldest
and most polluting vehicles .

To exempt vehicles from the CAZ

charge would remove any
incentive for owners to replace
their vehicles with cleaner
vehicles.

2. Age / Vehicle Licence Grant From 1st January 2020 no private hire From 1st January 2020 no private hire This is a significant change from
Current Policy Consultation Proposal Recommended Policy Commentary

No vehicle over the age of 8 years will vehicle may remain licensed after it vehicle may remain licensed after it our proposed policy, increasing
be granted a licence. reaches the age of 8 years. reaches the age of 12 years. the age limit for private hire
vehicles from 8 to 12 years.

This change has been

recommended to make our
policy consistent with that of
Wolverhampton City Council
which has an age policy of 12
years for private hire vehicles. If
Birmingham introduces a lower
age limit it would be creating an
incentive for Birmingham drivers
to acquire licences in
Wolverhampton. They would be
able to continue to work in
Birmingham under a
Wolverhampton operator.

3. Vehicle Licence Renewal This was not an aspect of the original No licences will be renewed after 1st This is a significant change from
proposals and has arisen out of January 2020 for any vehicle that is the proposal. Under the proposal
discussions with trade more than 12 years old. any vehicle that did not meet the
representatives. CAZ emissions standard on 1st
Any vehicle that is more than 12 years January 2020 would have to stop
old on 1st January 2020 will remain work on that day. The
licensed until the expiry of its vehicle recommended policy will see a
licence before 1st January 2021.
gradual reduction in the number
of vehicles that can continue to
Current Policy Consultation Proposal Recommended Policy Commentary

Vehicles that do not meet the CAZ work throughout 2020 instead of
emission standards for their type of a sudden loss of vehicles on 1st
fuel will not be exempted from paying January 2020.
the daily CAZ charge

4. Supplementary Test Plus / We will discontinue the From 1st January 2020 we will The recommendation is the
Exceptional Condition Test Supplementary Test Plus. discontinue the Supplementary Test same as the proposal with the
Plus (exceptional condition test) addition of the provision for
No vehicle over the age of 8 years will except for the case of CVRAS CVRAS retrofitted vehicles. This
have its licence renewed unless the retrofitted vehicles that are allowed will require all vehicles to be
vehicle is able to pass the to go over the 12 year age limit. replaced when they reach the
Supplementary Test Plus*, in which 12- year age limit (subject to the
case the vehicle licence may be exemption for CVRAS approved
renewed on a year by year basis, retrofitted technology) and will
subject to passing the Supplementary help to future-proof the fleet of
Test Plus on each occasion. licensed vehicles in relation to
*Also referred to as the ‘Exceptional compliance with more stringent
Condition Test’ emission standards.

5. Licence Transfer A licensed private hire vehicle can This ensures that the licence
only be replaced, swapped or changed transfer requirement is
A licensed private hire vehicle can with a vehicle that is less than 12 consistent with the new
only be replaced, swapped or changed years old. recommended age limit.
with a vehicle that is less than 8 years
old.
Current Policy Consultation Proposal Recommended Policy Commentary

6. MOT Test All vehicles are subject to a standard We do not propose to change
MOT test to determine its mechanical the requirement for MOT testing
All vehicles are subject to a standard fitness and a more stringent vehicles that are not more than
MOT test to determine its mechanical supplementary test dealing with the 12 years old.
fitness and a more stringent vehicle’s condition, appearance and
supplementary test dealing with the suitability prior to licensing.
vehicle’s condition, appearance and
suitability prior to licensing.

7. Approved CVRAS Retrofit With immediate effect we will allow This has been introduced to
Conversions any private hire vehicle to be fitted make our private hire vehicle
with approved CVRAS technology policy consistent with our
before 1st January 2024 by an hackney carriage policy.
approved CVRAS garage, (regardless However it should be noted that
of the age of the vehicle) provided the at the time of writing the CVRAS
garage is satisfied that the mechanical has not approved any technical
and structural condition of the vehicle solution for private hire vehicles.
is of a high enough standard that the
vehicle is safe, and those vehicles may The requirement for vehicles
over 12 to have two MOT tests
remain licensed until 31 December
2025, regardless of whether the cost and pass the Supplementary Test
of retrofitting the vehicle is paid for by Plus will offer the Committee
a government grant or privately by reassurance that these older
the vehicle owner. If it becomes vehicles are being maintained to
necessary to prioritise applications for a good standard.
government grant assistance towards
the cost of conversion we will give
Current Policy Consultation Proposal Recommended Policy Commentary

priority to the youngest vehicles.

Once a vehicle passes 12 years old it

would be subject to two MOTs a year
and our Supplementary Test Plus
(exceptional condition test).

8. Availability of CVRAS Approved This was not an aspect of the original A private hire vehicle that has been This has been introduced to be
Retrofit Technology proposals. accepted by a CVRAS approved garage consistent with the hackney
as being suitable for retrofit carriage policy recommendation
technology may continue to be in the event that lengthy waiting
licensed after 1st January 2020, lists might develop if a suitable
despite not having been converted technical solution is approved.
and despite the vehicle being over 12
years old, provided the owner can
evidence that they have a binding
contract with a CVRAS approved
garage for the conversion. This
exemption will not go beyond 31st
December 2020.

9. Payment of the CAZ Daily Charge This was not an aspect of the original Vehicles that are waiting for an Allowing drivers an exemption
proposals and has arisen out of approved CVRAS retrofit conversion from the daily CAZ charge
discussions with trade that have not been converted by 1st recognises the fact that the
representatives. January 2020 will be exempt from the inability of an owner to convert a
daily CAZ charge provided the owner vehicle may be due to factors
has entered into a binding contract beyond their control.
with a CVRAS approved garage for an
Current Policy Consultation Proposal Recommended Policy Commentary

approved conversion, until such time

that the conversion is completed.

10. Owner Conversions Any attempts by drivers to carry out Any attempts by drivers to carry out The recommendation is the
their own conversions (such as by their own conversions (such as by same as the proposal, but we
putting petrol engines into diesel putting petrol engines into diesel have emphasised that owners
vehicles) can only be done with the vehicles) can only be done with the own conversions do not provide
specific approval of Licensing and specific approval of Licensing and they the same benefits as a CVRAS
they will still be subject to the age will still be subject to the age rules. approved conversion. The
rules. Only a CVRAS approved conversion council does not guarantee that
gives the right to operate until an owner conversion will be
December 2025 and an owner recognised for the purposes of
conversion will not be financially the CAZ.
supported by the council

11. 2026 ULEV Requirement That from 1 January 2026 all licensed That from 1st January 2021 all newly This is a significant change.
vehicles (hackney carriage and licensed vehicles (vehicles licensed by Under the original proposal all
private hire) must be Ultra Low Birmingham for the first time) must be vehicles would have to be ULEV
Emission or Zero Emission Capable
Ultra Low Emission or Zero Emission or ZEC from 1st January 2026,
(ZEC) Vehicles. An Ultra-Low Emission
Vehicle is defined by the Office for Capable Vehicles. An Ultra-Low regardless of their age or of the
Low Emission Vehicles as emitting Emission Vehicle is defined by the fact that they would already be
less than 50g CO2/km and able to Office for Low Emission Vehicles as compliant with the minimum
travel at least 70 miles without any emitting less than 50g CO2/km and emission standards for the CAZ.
emissions at all. able to travel at least 70 miles without The new recommendation would
any emissions at all. only require vehicles being
licensed for the first time to be
ULEV or ZEC capable, but would
allow vehicles that we already
Current Policy Consultation Proposal Recommended Policy Commentary

license to continue until the

expiry of their age limit (which
would be 12 years).

A 2026 ULEV condition for new

vehicles would have meant that
there would be very low uptake
of ULEVs up to 2025, at which
point the majority of the fleet
will have been replaced meaning
there would probably not be
significant deployment of ULEV
private hire vehicles until
approximately 2035.

By bringing forward the ULEV

requirement on new vehicles
from 2026 to 2021 ensures a
reasonable level of ULEV
deployment by 2025.

12. 2030 ULEV Requirement From 2030 we will only grant new From 2030, if technology options are This change recognises that so
licences to fully electric vehicles on the market, to only grant new much might change between
licences to fully electric vehicles and now and 2030 in terms of
zero emission vehicles (e.g. battery technological development that
electric or hydrogen fuel cell vehicles). we would only seek to set out
To be reviewed before 2025. our direction of travel at this
stage, and that a firmer policy
Current Policy Consultation Proposal Recommended Policy Commentary

should be developed before

2025 when we will have better
knowledge about the availability
of vehicles with alternative fuels.